Data protection policy

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Contents

  1. Introduction.
  2. Personal data
  3. Collection, use and dissemination of personal data
  4. Withdrawing your consent
  5. Access to and correction of personal data
  6. Protection of personal data
  7. Accuracy of personal data
  8. Retention of personal data
  9. TRANSFERS OF PERSONAL DATA OUTSIDE THE EU, SWITZERLAND, HONG KONG SAR AND SINGAPORE.
  10. DATA PROTECTION OFFICER/ADVISOR ("DPO")
  11. USE OF COOKIES.
    1. WHAT IS A COOKIE?
    2. WHY DO WE USE COOKIES?
    3. HOW DO WE USE COOKIES?
  12. HOW DO WE USE YOUR DATA?
  13. HOW DO WE SHARE YOUR DATA?
  14. HOW DO WE STORE AND PROTECT YOUR DATA?
  15. HOW CAN YOU CONTROL COOKIES?
  16. YOUR RIGHTS.
  17. EFFECTIVE DATE AND CHANGES.
  18. ACCEPTANCE AND CONSENT

1 Personal data

Reference documents

Source

General Data Protection Regulation ("GDPR")                     

https://eur-lex.europa.eu/legal-content/FR/TXT/?uri=CELEX%3A32016R0679 

Information on the completely revised Data Protection Act (nLPD)

https://www.kmu.admin.ch/kmu/fr/home/faits-et-tendances/digitalisation/protection-des-donnees/nouvelle-loi-sur-la-protection-des-donnees-nlpd.html 

Swiss Federal Data Protection Act ("nLPD") 

https://www.fedlex.admin.ch/eli/cc/2022/491/fr 

Data Protection Ordinance (DPO)

https://www.fedlex.admin.ch/eli/oc/2022/568/fr 

Singapore Personal Data Protection Act (PDPA)

https://www.pdpc.gov.sg/Overview-of-PDPA/The-Legislation/Personal-Data-Protection-Act

Public consultation on the draft amendment to the Singapore Personal Data Protection Act

https://www.mci.gov.sg/media-centre/public-consultation/public-consultation-on-the-personal-data-protection-amendment-bill/ 

PDPA amendments - Bill N° 37/2020

https://www.parliament.gov.sg/docs/default-source/default-document-library/personal-data-protection-(amendment)-bill-37-2020.pdf 

Personal Data (Privacy) Ordinance of Hong Kong SAR ("PDPO")

Cap. 486 Personal Data (Privacy) Ordinance (elegislation.gov.hk)

https://www.elegislation.gov.hk/hk/cap486!en@2018-04-20T00:00:00

Antaes Consulting SA is a Swiss consulting firm specializing in management and technology. ANTAES has three offices in Switzerland (Geneva, Lausanne and Zurich) and two subsidiaries, Antaes Asia Pte Ltd in Singapore and Antaes Asia (Hong Kong) Limited in Hong Kong SAR.

 

This Data Protection Policy ("notice") sets out the basis on which

  • Antaes Consulting SA.,
  • Antaes Asia Pte. Ltd,
  • and Antaes Asia (Hong Kong) Limited

("ANTAES", "we", or "our") may collect, use, share or process the personal data of data subjects such as customers, employees or applicants in accordance with :

  • the European Data Protection Regulation ("RGPD"),
  • the new Swiss federal law on data protection ("nLPD"),
  • the new Data Protection Ordinance ("OPDo"), 
  • Singapore's Personal Data Protection Act (PDPA) and its revision ("Bill N° 37/2020" or "amended PDPD")
  • and Hong Kong's Cap. 486 Personal Data (Privacy) Ordinance (PDPO).

By default, the most restrictive regulation will be applied by ANTAES.

 This notice applies to all personal data in our possession and data in the possession of organizations with which we are involved.

 

2 Personal data

As used in this Notice and defined in Article 4 of the RGPD : 

"Data Subject", i.e. an identified or identifiable natural person who (a) has contacted us by any means to find out more about our services or (b) could or has entered into a contract with us for the provision of our services.

"Personal data", i.e. any information that directly or indirectly identifies a natural person such as a customer or applicant (e.g. name, telephone number, photograph, date of birth, municipality of residence, IBAN, etc.).

Where the context permits, all other terms used in this notice shall have the meaning given by the RGPD, the nLPD, the amended PDPA and Cap. 486 (PDPO).

 

3 Collection, use and distribution of personal data

Usually, we do not collect your personal data unless (a) it has been voluntarily provided to us directly by you, a partner or job site that have been duly authorized and after (b) you (or your authorized representative) have been informed of the purposes for which your data is being collected or, (c) the collection and use of your personal data without your consent is permitted or required by the RGPD, nLPD, , PDPA, Cap. 486 (PDPO) or any other law. In the event of the collection of additional personal data and prior to the use of such data for a purpose not notified to you (unless permitted or authorized by law), we must obtain your prior consent. 

We collect and use your personal data for the following purposes:

(a) to perform our obligations in accordance with the services requested by you;

(b) verify your identity ;

(c) respond to and process any request, application or claim made by you;

(d) manage your relationship with us; 

(e) process payments or transactions relating to you;

(f) send you marketing information about our services, including marketing events or other initiatives;

(g) to comply with applicable laws and/or regulations and/or codes of conduct or to facilitate investigations by government law enforcement and security agencies and/or regulatory authorities;

(h) for any other purposes for which you have provided us with your personal data;

(i) to transmit your data to the various Antaes Consulting SA entities in Switzerland and Singapore, to our customers and prospects or to any other third-party service provider for the purposes set out above;

(j) for any other activity related to the above purposes.

We may pass on your personal data:

  1. insofar as such dissemination is necessary for the performance of the services you have requested from us; or
  2. any other of our service providers engaged in the above-mentioned functions. 

The purposes mentioned in this notice may continue to apply even if your relationship with us has been modified or terminated, for a reasonable period of time.

 

4 Withdrawing your consent

Your consent to the collection, use and dissemination of your personal data will remain valid until you request its deletion in writing. At any time, you may withdraw your consent and request that we cease using and/or distributing your personal data for any of the purposes and uses mentioned in this notice by submitting your request in writing or by email to our Data Protection Officers ("DPO") in Switzerland or Singapore whose contact details are available below.

 


ANTAES Consulting SA.

DPO

Avenue des Morgines 12,

1213 Petit-Lancy

Switzerland

 

Std: +41 022 560 72 72

DPO@antaes.ch



ANTAES Asia Pte. Ltd.

DPO

1 Marina Boulevard, Level 20

Singapore 018989

 

M: +65 9640 8053

F: +65 6990 9585

DPO@antaesasia.com


At any time you may exercise your right to obtain from ANTAES the erasure, as soon as possible, of personal data concerning you or "right to be forgotten" as provided for in Article 17 of the RGPD, Article 17 of the nLPDand Sections 16 and 25 of the PDPA.

Upon receipt of your written request to withdraw consent, we may need a reasonable period of time (depending on the complexity of the request and its impact on our relationship) to process your request and notify you of the legal and other consequences of your rights and responsibilities to us. We will endeavor to process your request as soon as possible after receipt.

While we respect your decision to withdraw consent, please note that depending on the nature and scope of your request, we may no longer be able to provide you with our services and, in this case, we would need to inform you in advance. Should you decide to withdraw your consent, please inform us in writing as described above. 

Please note that withdrawal of consent does not affect our right to continue to collect, use and disclose personal data where collection, use and disclosure without consent is permitted or required under applicable laws and regulations.

 

5 Access to and correction of personal data

As provided in Article 17 of the RGPD, Article 32 of the nLPD and PART V, Sections 21 and 22 of the PDPA, Data Protection Principle 1 and Part 5 of Cap. 486 (PDPO), if you wish to make (a) a request for access to a copy of your personal data in our possession or obtain information as to its use or dissemination, or if you wish to make (b) a request for correction or updating of such data, you may make the request in writing or by email to our DPOs in Switzerland or Singapore (also valid for Hong Kong SAR) whose contact details are available below.

 

We will respond to your request as soon as possible. If, however, we are unable to respond to your request within thirty (30) working days of receipt, we will inform you in writing within thirty (30) working days. If we are unable to provide you with your personal data or correct it according to your request, we would have to specify the reasons why, unless this is not required of us under the GDPR, the nLPD, the amended PDPA or CAP 486 (PDPO).

 

6 Protection of personal data

To protect your personal data from unauthorized access, collection, use, dissemination, copying, modification, disclosure or similar risks, we have put in place appropriate administrative, physical and technical measures such as up-to-date antivirus protection, encryption and the use of privacy filters to protect any archiving and transmission internally or to our authorized service providers of your personal data on a need-to-know basis only (Article 25 of the RGPD, Article 7 of the nLPD, Section 24 of the PDPA and Schedule 1 of Cap. 486(PDPO)).

While security cannot be guaranteed, we make every effort to protect the confidentiality of your data and are constantly reviewing and improving our information security measures.

 

7 Accuracy of personal data

In general, we rely on the accuracy of the data you (or your authorized representative) have provided to us(Article 5 of the RGPD, Article 6 of the nLPD, Section 23 of the PDPA and Principle 1 and 2 of Cap. 486 (PDPO)). To ensure that your data is up-to-date, complete and accurate, please inform our DPOs in Switzerland or Singapore, whose contact details are specified below, in writing or by email of any changes to your personal data.

In the event of inaccurate or erroneous data, this will be updated on the basis of any information you may provide.

 

8 Retention of personal data

We may keep your personal data for as long as necessary to accomplish the purpose for which it was collected, or as required or permitted by applicable law as well as by the new statute of limitations that came into effect on January 1, 2020.

We will stop storing your personal data, or remove any means of associating it with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which your data was collected and is no longer required for legal or commercial purposes.

 

9 TRANSFERS OF PERSONAL DATA OUTSIDE THE EU, SWITZERLAND, HONG KONG SAR AND SINGAPORE

As we are engaged in cross-border data transfers between Switzerland, the European Union, Hong Kong SAR and Singapore (via, among others, the use of online IT services, cloud-based services, remote access services or shared HR databases), we have put in place legitimate data transfer mechanisms to ensure that your personal data receives a standard of protection at least comparable to those under the GDPR (Article 44), nLPD (Article 16), PDPA (Section 26) and Part. 6 and article 33 of Cap. 486 (PDPO).

If we need to transfer your personal data outside Switzerland, the EU, Hong Kong SAR or Singapore, we will do so with your consent and take all necessary measures compatible with the requirements of the GDPR, nLPD, amended PDPA and Cap. 486 (PDPO).

 

10 DATA PROTECTION OFFICER ("DPO")

As provided by Articles 38 and 39 of the RGPD, Article 10 of the nLPD and the PDPA, you may contact our Advisors / Data Protection Officers ("DPOs") in Switzerland and Singapore in writing or by email for any questions relating to your personal data and/or our data protection policy or for any other queries, as follows: 

 


ANTAES Consulting SA.

DPO

Avenue des Morgines 12,

1213 Petit-Lancy

Switzerland

 

Std: +41 022 560 72 72

DPO@antaes.ch



ANTAES Asia Pte. Ltd.

DPO

1 Marina Boulevard, Level 20

Singapore 018989

 

M: +65 9640 8053

F: +65 6990 9585

DPO@antaesasia.com


 

Our Singapore-based DPO also acts as DPO for our Hong Kong SAR office.

 

11 USE OF COOKIES

The purpose of this Cookie Statement is to explain how ANTAES uses cookies and similar technologies to recognize you when you visit our website www.antaes.ch ("Website"). It aims to explain what these technologies are, why we use them, and what rights you have to control how we use them. 

Our website is hosted and managed in Switzerland.

If we ask you to provide personal data, i.e. any information relating to an identified or identifiable natural person, via our website, you can be assured that your personal data will be processed in accordance with our Data Protection Policy.

 

11.1 WHAT IS A COOKIE?

A cookie is a small text file that is downloaded to your computer or mobile device when you visit a website. Cookies are widely used by website owners to ensure the smooth running of the site or to enable more efficient operation, as well as to obtain information about your preferences.

 

11.2 WHY DO WE USE COOKIES?

We use third-party cookies on our website for navigational and analytical purposes, as detailed below:

Cookie types

How to refuse them 

Functional / 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.

Restrict the use of cookies in your browser settings (on your computer or phone) or by using private browsing.

You can also delete cookies placed on your device by websites.

 

Analytics: Analysis and personalization cookies:These cookies collect information used in aggregate form to help us understand how our website is used and to measure the effectiveness of our marketing campaigns, or to help us tailor our website to you.

https://policies.google.com/privacy

To refuse these cookies, please follow the instructions below under the heading "How can you control cookies?" 

You can also click on the unsubscribe link below: 

https://tools.google.com/dlpage/gaoptout/

Type

Cookie

Description

Duration

Functional

__cf_bm

to support Cloudflare Bot Management.

(via Glassdoor.ch)

30 minutes

Functional

wpml_browser_redirect_test

to test if cookies are enabled on the browser.

session

Functional

_icl_visitor_lang_js

to store the redirected language.

1 day

Analytics

_ga

To calculate visitor, session and campaign data and track site usage for the site's analytics report. The cookie stores information anonymously and assigns a randomly generated number to recognise unique visitors.

1 year 1 month 4 days

Analytics

_gid

To store information on how visitors use a website while also creating an analytics report of the website's performance. Some of the collected data includes the number of visitors, their source, and the pages they visit anonymously.

1 day

Analytics

_gat_UA-*

For user behavior tracking.

1 minute

 

11.3 HOW DO WE USE COOKIES?

You can access and use our website without providing us with your personal data.

ANTAES may collect your personal data via our website in two specific ways:

  1. ✔ When you apply for one or more of our job offers;
  2. ✔ When you use our contact form for any question related to our services. 

 In such cases, the following personal data may be collected: surname, first name, address, telephone number, e-mail address, job title.

Other information may also be collected automatically via cookies when you access and use our website. We use traffic logs via Google Analytics to identify which pages of the ANTAES website are consulted in order to adapt them to your needs. We use this data for statistical analysis purposes only. Cookies do not give us access to your computer or to your data, other than that which you have chosen to share with us.

To give visitors to the ANTAES website the ability to prevent Google Analytics from using their personal data, we have defined an opt-out option in our Data Protection Policy. You can choose to accept or decline cookies at any time by modifying your web browser controls.   

 

11 HOW DO WE USE YOUR DATA?

Personal data collected from our ANTAES website is used for two purposes:

1. Marketing

✔ To measure the use of the ANTAES website via Google Analytics in an anonymized way. 

 

2. Communication Standard

✔ To respond to your inquiries and/or applications via our online contact form or the "Contact Us" section of our website.  

 

12 HOW DO WE SHARE YOUR DATA?

As an international consulting company, ANTAES may share your personal data collected via our website internally between its offices in Geneva, Lausanne, Zurich, Hong Kong SAR and Singapore.

ANTAES may use the services of third parties for certain tasks, such as technical support for our website or application management. To this end, we may share your personal data with these partners.

ANTAES will never sell or rent your personal data to third parties.

 

13 HOW DO WE STORE AND PROTECT YOUR DATA?

We are committed to processing your personal data in a secure manner. In order to prevent unauthorized access or data leakage, we have put in place appropriate physical, electronic and managerial procedures to safeguard and secure the data we process. In particular, ANTAES adheres to a documented Data Protection Policy.

This ensures that data is stored in compliance with the RGPD, the nLPD, the amended PDPA and Cap. 486 within the limits of the purpose for which it was collected.

 

14 HOW CAN YOU CONTROL COOKIES?

You have the right to decide whether or not to accept cookies. You can set your web browser to accept or reject cookies.

If you choose to disable cookies, you may continue to use our website, but your access to certain features and sections of the site may be restricted. 

 

15 YOUR RIGHTS

If you change your mind and no longer wish us to process your personal data for recruitment purposes or if you have any questions about our use of cookies and other technologies, please email our DPOs whose contact details are listed above. 

If you would like more information about your personal data that we have collected, if you believe that this data is incorrect or incomplete, or if you would like us to delete your data, please send an e-mail to DPOs using the addresses provided above.


ANTAES Consulting SA.

DPO

Avenue des Morgines 12,

1213 Petit-Lancy

Switzerland

 

Std: +41 022 560 72 72

DPO@antaes.ch



ANTAES Asia Pte. Ltd.

DPO

1 Marina Boulevard, Level 20

Singapore 018989

 

M: +65 9640 8053

F: +65 6990 9585

DPO@antaesasia.com


Our Singapore-based DPO also acts as DPO for our Hong Kong SAR office.

 

16 EFFECTIVE DATE AND CHANGES

This notice applies in addition to any other notices, contractual clauses and consent that apply to the collection, use and dissemination of your personal data by us and as set out in Article 4 of the GDPR, Article 5 of the nLPD, Sections 13 and 14 of the PDPA and Cap. 486.

 

We may revise this manual without prior notice. The revision history is detailed in this notice. Your continued use of our services constitutes your acknowledgement and acceptance of these changes.

 

Effective date: September 21, 2018

Last update: October 20, 2023