POSITIVE COATING

CONFIDENTIALITY POLICY

ABOUT US

POSITIVE COATING SA is a company registered in the Neuchâtel Canton Corporate Register, Switzerland, under number CHE-112.093.782, and is headquartered at Rue des champs 12, 2300 La Chaux-de-Fonds, Switzerland (hereafter, referred to as “us”). We run the website www.positivecoating.ch.

RESPONSIBLE JEWELLERY COUNCIL (RJC)

POSITIVE COATING is a member of the Responsible Jewellery Council (RJC), an organisation bringing together more than 260 professionals worldwide, committed to upholding ethics, human rights, social rights and good environmental practices throughout the gold and diamond production chain, from the mines to the retail sector. The Council has developed the RJC system, a certification process which is applicable to all member businesses involved in the gold and diamond jewellery logistics chain. In order to earn the status of Certified Member under the RJC system, all Commercial Members must undergo an audit conducted by accredited third-party auditors, to verify their compliance with the RJC Code of Practice.

DECLARATION OF CONFIDENTIALITY

POSITIVE COATING attaches great importance to your personal data. The purpose of the present declaration (“Declaration of Confidentiality”) is to inform you of how we process any personal data we might collect from you when you access our online and offline services, including the personal data that we collect by means of our various channels, such as our website, social networks, and the events that we organise.

The Swiss company POSITIVE COATING SA is responsible for defining the overall personal data processing and management policy for commercial and marketing purposes, and in accordance with the General Data Protection Regulation no. 2016/679 adopted in the European Union (“GDPR”), and Swiss Federal Act of 19 June 1992 on Data Protection (“LPD”), the Declaration of Confidentiality is governed and interpreted by the GDPR and LPD, under the supervision of the Federal Overseer for Data Protection and Transparency, insofar as the Swiss company POSITIVE COATING SA bears responsibility

You are invited to take the time to read the Declaration of Confidentiality in full. We are available to answer any questions you have at info@positivecoating.ch, especially in terms of exercising your rights with regard to your personal data.

PERSONAL DATA THAT WE COLLECT

The Declaration of Confidentiality is applicable to any personal data that we might collect from you or about your (see below), from the following sources:

  • Visiting our websites, in particular when completing a form or using a service (submitting applications), a feature or resources published on our site. You will be invited to identify yourself, but you can also visit our site without registering;
  • Electronic and telephone communications between POSITIVE COATING and you;
  • Purchasing a POSITIVE COATING product or requesting a service;
  • Calls to POSITIVE COATING customer service centres;
  • Submitting online applications for job vacancies at POSITIVE COATING;
  • Data that you share publicly through your interaction with POSITIVE COATING on social networks (e.g., when you “like” a POSITIVE COATING page on the social networks).

We might collect various types of informations from you, according to the purpose and nature of your interaction with POSITIVE COATING (online, offline, by phone, etc.), as set out below:

  • Personal contact details: this means any information that you provide which would enable us to contact you, such as your name, e-mail address, postal address or phone number, as well as the history of your purchases and after-sales services that you have requested.
  • Demographic information: any information describing your demographic and behavioural characteristics. This may mean, for example, your gender, nationality, geographic location (e.g. postcode), your preferred language, other preferences, such as your professional situation (professional title, company/employer, professional contact details).
  • Data on traffic and use of our site: when you interact with our site, we might collect traffic data by means of automated data collection technologies, involving in particular dialogue between the website server and your browser. Traffic data may include the browser name and the type of device you are using, as well as technical data on your connection mode to our site, in particular your operating system, the IP address of your device connected to the Internet, the identifier of your access point to the Internet, the date and time of your last visit, and the Internet access providers you use. These data are used for statistical purposes, and their analysis enables us to improve our site, offer a customised browsing experience, tailored to your preferences and your areas of interest, e.g. by directly displaying the pages in your preferred language the next time you visit. This information is entered using automated technologies such as cookies (browser cookies) and web tags (such as Java Script); it is also collected by means of external tracking services (Google Analytics).
  • Links to other websites. Our site may contain or use links to third-party websites (in particular advertising, partners or social networks). These third-party websites have their own confidentiality policy (particularly in terms of cookie use), which we would advise you to look up. We do not accept any liability with regard to the confidentiality policies of such third-party websites, which you access at your own risk.
  • Privacy and protection of minors. Our site is not intended for users aged under 16. We do not knowingly collect personal data on children aged under 16. If you are a parent or guardian, and you are aware that your child has provided personal data, please contact us. If we realise or are informed that we have collected personal data on a child aged under 16 without verification of parental consent, we will take measures to delete this information from our servers, unless bound by a legal obligation to retain it (accounting or purchase-related data, data required for guarantees applicable to or management of repair requests, etc.). In every case, users aged under 16 who have provided personal data have a discretionary right to erase their data, which they can exercise at any time without providing a reason, on their own or through their habitual guardian, by contacting us at the address stated in chapter VIII “Contact us”. Erasure requests will be processed under the conditions and reservations described above.

USE OF YOUR PERSONAL DATA

We collect and use your personal data for the purposes described below. Please note that the types of use figuring below depend on how you use our services, and do not systematically relate to each user:

  • Processing your orders, purchases (including any VAT reimbursement requests) and deliveries;
  • Answering your queries, questions and/or requests of all kinds;
  • Regularly sending you information, especially on POSITIVE COATING, news, our events, with your consent if required;
  • Talking with you via social media if you interact with the third-party social network features, such as the “like” functions. We recommend looking up the conditions of use of the third-party networks concerned, to learn about these features, and if applicable terminate your subscription;
  • Managing our site and your accounts, including customising your user experience on our site, while also presenting content specific to POSITIVE COATING which matches your interests.
  • Producing reports and statistics, especially for the purposes of measuring traffic on the site;
  • Managing the recruitment process for job vacancies at POSITIVE COATING;

HOW WE PROTECT YOUR PERSONAL DATA

We have implemented appropriate security practices and measures in terms of processing personal data, to prevent any unauthorised third-party access to your personal data, and protect them from being altered, divulged or destroyed. These security measures consist mainly in strict control of access and administrators, encryption of all personal data entered in our customer relations and potential customer databases, a periodic review of access, constant supervision of the infrastructure, as well as a risk analysis and remediation strategy.

Nonetheless, although we make every effort to protect your personal data, we cannot guarantee the safety of the information transmitted to our site in transit via the Internet by means of a non-secure protocol.

SHARING YOUR PERSONAL DATA

We undertake not to sell, trade, rent or transfer in any way your personal data without your consent (given after receipt of prior notification).

For the reasons described in chapter II above, we may share with our commercial and advertising partners copies of generic demographic information, free from any direct identifying information of our visitors, for statistical purposes.

We always require that these third parties provide sufficient guarantees of confidentiality and security, and take the necessary organisational and technical measures to protect your personal data in accordance with the applicable legislation. To ensure a sufficient level of protection, the transfers are governed, if necessary, by the contractual clauses in force adopted by the European Commission or via mechanisms validated thereby, or by the competent authorities responsible for personal data protection within the European Economic Area, and if applicable, further measures which might be required in other jurisdictions. Furthermore, service providers are not authorised to access your personal data and only make use of them for the specific tasks they have been assigned, based on our instructions.

Transfer to third parties for legal reasons: we might communicate personal data to satisfy legal requirements, meet demand from a competent body responsible for applying the law, exercising our rights or defending ourselves against a complaint or legal procedure, or to provide proof, to protect the interests of a POSITIVE COATING entity, and combat fraud.

RETENTION OF YOUR PERSONAL DATA

We retain your personal data for the period necessary to satisfy the various purposes defined in chapter II above, except where the law permits or demands that we keep them for longer.

These maximum times are applicable unless you request that your data be erased or excluded from use before these times expire, for a reason compatible with any legal obligation for retention to which POSITIVE COATING might be subject.

YOUR RIGHTS TO YOUR PERSONAL DATA

Access to personal data, modification, updating and deletion: if stipulated by the applicable law, you can request access to personal data about you held by POSITIVE COATING, consult them and obtain a hard or electronic copy, and request that your personal data be corrected, limited, updated or deleted, or excluded from processing. You can exercise these rights via a written request, accompanied by a copy of your ID document, with which you interact, to POSITIVE COATING, at either the postal or e-mail address indicated in chapter VIII “Contact us” below. We will make every effort to provide you with the personal data concerned, correct or erase them, according to your request and under the conditions stipulated by the applicable law.

Please note that in certain cases, we may not be able to delete your personal data without also deleting your user account. It is also possible that we might have to retain some of your personal data after your deletion request, in order to comply with our legal or contractual obligations. We may also be authorised by the applicable law to retain some of your personal data to meet our legal obligations.

Opt-out: you may also at any time ask to stop receiving information or offers from us, either by following the unsubscription process described in the messages you will receive from us, or by writing to us at the address indicated in chapter VIII “Contact us” below.

Portability: given the specificity of the products designed and marketed by POSITIVE COATING, as well as the associated services provided, POSITIVE COATING may not, except by an individual and specific written request addressed to us, and justified by a legitimate reason, apply portability as defined by the GDPR.

Complaints to a monitoring authority: without prejudice to any other legal remedy, you also have the right to make a complaint to the competent European Union monitoring authority for application of GDPR rules, or to the Federal Overseer for Data Protection and Transparency, under the conditions set out by the LPD.

MODIFICATIONS TO OUR DECLARATION OF CONFIDENTIALITY

We reserve the right to modify the Declaration of Confidentiality at any time. You will be informed in advance via publication of a notification on our website’s home page. We encourage you to regularly look up this page to remain informed of any modifications, and of any measures we take to protect the personal data we collect. You agree and recognise that it is incumbent on you to regularly visit our site to remain informed of any modifications made to it.

CONTACT US

For any questions on this Declaration of Confidentiality, please contact us at the e-mail address info@positivecoating.ch, or our postal address POSITIVE COATING SA, Rue des champs 12, 2300 La Chaux-de-Fonds, Switzerland.

This document was updated on 27 January 2021.