Antaes Consulting SA is a Swiss consulting company specializing in management and technology. ANTAES has three offices in Switzerland (Geneva, Lausanne and Zurich) and a subsidiary, Antaes Asia, which has two offices in Singapore and Hong Kong SAR.
This Data Protection Notice (“Notice”) sets out the basis which both ANTAES Consulting SA. And ANTAES Asia Pte. Ltd. (“ANTAES”, “we”, “us”, or “our”) may collect, use, disclose or otherwise process personal data of data subjects such as our customers, employees or candidates in accordance with the European General Data Protection Regulation (“GDPR”), the New Swiss Federal Act on Data Protection (‘’nFADP’’, in French, ‘’nLPD’’), The new Data Protection Ordinance (« OPDo »), the Singaporean Personal Data Protection Act (“PDPA”) and its amendments (“Bill N° 37/2020” or “amended PDPA”), as well as the Hong Kong Personal Data (Privacy) Ordinance (“Cap. 486 Personal Data (Privacy) Ordinance”). By default, the most stringent regulation will be applied by ANTAES.
This Notice applies to personal data in our possession or under our control, including personal data in the possession of organizations that we have engaged to collect, use, disclose or process personal data for our purposes.
1 PERSONAL DATA
As used in this Policy and defined in Article 4 of the GDPR:
“Data Subject”: an individual who (a) has contacted us through any means to find out more about any services we provide, or (b) may, or has, entered into a contract with us for the supply of any of our services.
“Personal Data”: any information directly or indirectly identifying a person such as a client or a candidate (e.g. name, telephone number, photograph, date of birth, municipality of residence, IBAN, …).
Whenever possible, all other terms used in this Notice shall have the meanings given by the GDPR, FADP, P-LPD, amended PDPA, and Cap. 486.
2 COLLECTION, USE, AND DISCLOSURE OF PERSONAL DATA
We generally do not collect your personal data unless (a) it is provided to us voluntarily by you directly or via a third party or job boards who have been duly authorized by you to disclose your personal data to us (your “authorized representative”) after (b) you (or your authorized representative) have provided written consent to the collection and usage of your personal data for those purposes, or (c) the collection and use of personal data without consent is permitted or required by the GDPR, the PDPA, the P-LPD, the PDPA, the Bill N° 37/2020, Cap. 486 or other laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose that has not been notified to you (except where permitted or authorized by law).
We may collect and use your personal data for any or all of the following purposes:
(a) performing obligations in the course of or in connection with our provision of the services requested by you;
(b) verifying your identity;
(c) responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
(d) managing your relationship with us;
(e) processing payment or credit transactions;
(f) sending your marketing information about our services including notifying you of our marketing events, initiatives, membership, and rewards schemes and other promotions;
(g) complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;
(h) any other purposes for which you have provided the information;
(i) transmitting to Antaes’ offices and headquarters in Switzerland, to its clients, prospects or any unaffiliated third parties including our third-party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes; and
(j) any other business purposes related to or in connection with the above.
We may disclose your personal data:
(a) where such disclosure is required for performing obligations in the course of or in connection with our provision of the services requested by you; or
(b) to third-party service providers, agents, and other organizations we have engaged to perform any of the functions listed in clause 5 above for us.
The purposes listed in the above clauses may continue to apply even in situations where your relationship with us has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under any contract with you).
3 WITHDRAWING YOUR CONSENT
The consent that you provide for the collection, use, and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officers (“DPOs”) in Switzerland or in Singapore at the contact details provided below.
At any time, you can exercise your right to obtain from Antaes the erasure of your personal data without undue delay (‘right to be forgotten’ as defined in Article 17 of the GDPR, Article 17 nFADP (nLPD) and Sections 16 and 25 of the PDPA).
Upon receipt of your written request to withdraw your consent, we may require a reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within ten (10) business days of receiving it.
Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described above.
Please note that withdrawing consent does not affect our right to continue to collect, use, and disclose personal data where such collection, use, and disclose without consent is permitted or required under applicable laws.
4 ACCESS TO AND CORRECTION OF PERSONAL DATA
As stated in the Article 17 of the GDPR, Articles 32 of the FADP (nLPD), and in PART V, Sections 21 and 22 of the PDPA, as well as Part 5 of Cap.486, if you wish to make (a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or (b) a correction request to correct or update any of your personal data which we hold about you, you may submit your request in writing or via email to our DPOs in Switzerland or in Hong Kong SAR at the contact details provided below.
Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.
We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except if we are not required to do so under the GDPR, the nFADP, amended PDPA, , or Cap 486).
5 PROTECTION OF PERSONAL DATA
To safeguard your personal data from unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as up-to-date antivirus protection, encryption and the use of privacy filters to secure all storage and transmission of personal data by us and disclosing personal data both internally and to our authorized third-party service providers and agents only on a need-to-know basis (Article 25 of the GDPR, the Article 7 nFADP, Section 24 of the PDPA and Schedule 1 of Cap. 486).
You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
6 ACCURACY OF PERSONAL DATA
We generally rely on personal data provided by you (or your authorized representative). In order to ensure that your personal data is current, complete and accurate, please inform us if there are any changes to your personal data by informing our DPOs in writing or via email at the contact details provided below (Article 5 of the GDPR, Article 6 nFADP, Section 23 of the PDPA, and Principle 2 of Cap. 486).
7 RETENTION OF PERSONAL DATA
We may retain your personal data for as long as it is necessary to fulfill the purpose for which it was collected, or as required or permitted by applicable laws, as well as the new statute of limitations that came into effect on January 1, 2020.
We will cease to retain your personal data or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected and is no longer necessary for legal or business purposes.
8 TRANSFERS OF PERSONAL DATA OUTSIDE OF THE EU, SWITZERLAND, HONG KONG SAR AND SINGAPORE
As we are engaged in Cross-Border Data Transfers between Switzerland, Singapore, Hong Kong SAR and the EU (via. the use of online IT services, cloud-based services, remote access services or global HR databases—among others), we have implemented lawful data transfer mechanisms to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA and the GDPR as stated in the Article 44 of the GDPR, the Article 16 of the nFADP, in Section 26 of the PDPA, and Part. 6 of Cap. 486.
If we have to transfer your personal data to countries outside of Switzerland, Singapore, Hong Kong SAR or the EU, we will obtain your consent for the transfer to be made and we will take steps to place a data transfer mechanism that complies with the requirements of the GDPR, the nFADP, the amended PDPA, and of Cap. 486.
9 DATA PROTECTION OFFICER/AGENT
As set out in the Articles 38 and 39 of the GDPR, article 10 in the nFADP, and in the PDPA, you may contact by writing or via email our Data Protection Officers/Agent (“DPOs”) in Switzerland or in Singapore if you have any inquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, in the following manner:
|ANTAES Consulting SA.|
Avenue des Morgines 12,
Std: +41 022 560 72 72
ANTAES Asia Pte. Ltd.
Room 805, 8/F, Harbour Crystal Centre,
No. 100 Granville Road
Tsim Sha Tsui,
Kowloon, Hong Kong SAR
Our Hong Kong SAR-based DPO also has DPO responsibilities for our Singapore office.
10 COOKIES STATEMENT
ANTAES Consulting SA. (hereafter “ANTAES”, we”, “us”, or “our”) is a Swiss company providing advisory services, whose offices are located in Geneva, Lausanne, Zurich, and Singapore. This cookies policy relates to the collection of information through cookies when you visit our website www.antaes.ch (“our website”). The ANTAES website is hosted and managed in Switzerland.
Should we ask that you provide your personal data, i.e. information which relates to you as an identified or an identifiable natural person, through our website, you can be assured that this data will only be processed in accordance with our Data Protection Policy.
10.1 WHAT ARE COOKIES?
Cookies are small files which ask permission to be placed on your computer’s hard drive. They help analyze web traffic and allow web applications to respond to you as an individual.
Cookies can be accessed either by the web server or your computer. They allow the server to tailor its operations to your needs, likes, and dislikes by gathering and remembering information about your preferences.
We use third-party cookies via our website for navigation or analytical purposes as detailed below:
|Types of cookie||How to refuse|
|Necessary cookies help make our website usable by enabling basic functions such as page navigation and access to secure areas of the website. The website cannot function properly without these cookies.||Limit the useof cookies in your browser settings (on your computer or phone) or by using private browsing.|
You can also delete cookies placed by websites on your device.
|Analytics and customization cookies: These cookies collect information that is used either in aggregate form to help us understand how our Website is being used or how effective our marketing campaigns are, or to help us customize our Website for you.||To refuse these cookies, please follow the instructions below under the heading “How can you control cookies?”|
Alternatively, please click on the relevant opt-out link below:
You can access and use our website without providing us with your personal data. ANTAES may collect your personal data through the website in two specific situations:
- When you apply to one or several of our job offers;
- When you fill out our contact form for requests related to our services.
In these instances, the following personal data may be collected: name, surname, address, telephone number, email address, job title.
Some information may also be collected automatically through cookies when you access and use our website. We use traffic log cookies via Google Analytics to identify which ANTAES website pages are being used in order to tailor them to your needs. We only use this information for statistical analysis purposes. Cookies do not give us access to your computer or any information about you, other than the data you choose to share with us.
To provide ANTAES website visitors the ability to prevent their data from being used by Google Analytics, we have defined an opt-out option in our Data Protection Policy. You can choose at any time to accept or decline cookies by modifying your browser setting.
11 HOW WE USE YOUR DATA
The data collected through ANTAES website are used for two kinds of purpose:
- to measure the business usage of ANTAES website via Google Analytics, anonymously.
- to respond to your inquiries and/ or job application sent via our contact form or job board.
12 HOW WE SHARE YOUR DATA
As a global consulting company, ANTAES may share the personal data it collects through the website internally, among its offices in Geneva, Lausanne, Zurich, Hong Kong SAR, and Singapore.
ANTAES may employ the services of third parties to support us with certain tasks, such as web technical support or management of applications. To this end, we may also share your data with our third-party service providers, to perform services on our behalf.
ANTAES does not sell or lease your personal data to third parties.
13 HOW WE STORE AND PROTECT YOUR DATA
We are committed to ensuring that your information is secure. In order to prevent unauthorized access or disclosure, we have put in place suitable physical, electronic, and managerial procedures to safeguard and secure the information we process. In particular, ANTAES adheres to a documented information Data Protection Policy.
This ensures that the data are stored in compliance with the GDPR, the nFADP, the amended PDPA and Cap. 486 and within the limits of the purpose for which they were collected.
14 HOW CAN YOU CONTROL COOKIES ?
If you choose to reject cookies, you may still use our website though your access to some functionality and areas of our website may be restricted.
15 YOUR RIGHTS
If you wish to obtain details relating to the personal data which we have collected from you, if you believe that these data are incorrect or incomplete and would like to have them corrected, or if you would like that we erase your data, please send an email to our DPOs using the contact details provided above.
16 EFFECT OF NOTICE AND CHANGES TO NOTICE
This Notice applies in conjunction with any other notices, contractual clauses, and consent clauses that apply in relation to the collection, use, and disclosure of your personal data by us as stated in Article 4 of the GDPR, the Article 3 of the P-LPD and in Sections 13 and 14 of the PDPA, and Cap. 486.
We may revise this Notice from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Notice was last updated. Your continued use of our services constitutes your acknowledgment and acceptance of such changes.
Effective date: September 21st 2018
Last updated: October 20th 2023