PRIVACY POLICY

Last update: 16/01/2024

Your Personal Data and privacy matters. We are committed to safeguarding your Personal Data and protecting your privacy. Our aim is not just to comply with privacy law, it’s to earn your trust.

01. Introduction
          01.1. Who are we?
         01.2. Why this privacy policy?
         01.3. How does this privacy policy apply to you?
         01.4. Who is involved in the collection and handling of your Personal Data?
02. What Personal Data do we collect and for how long?
         02.1. Website visitors
                  02.1.1. Purposes of data processing
                  02.1.2. Legal basis for processing
                  02.1.3. Categories of Personal Data
                  02.1.4. Categories of data recipients 
                  02.1.5. Retention periods
         02.2. Candidates
                  02.2.1. Purposes of data processing
                  02.2.2. Legal basis for processing
                  02.2.3. Categories of Personal Data
                  02.2.4. Categories of Data Recipients 
                  02.2.5. Retention periods
         02.3. Ekkiden employees
                  02.3.1. Purposes of data processing
                  02.3.2. Legal basis for processing
                  02.3.3. Categories of Personal Data
                  02.3.4. Categories of Data Recipients
                  02.3.5. Retention periods
         02.4. Suppliers, partners and service providers
                  02.4.1. Purpose of data processing
                  02.4.2. Legal basis for processing
                  02.4.3. Categories of Personal Data
                  02.4.4. Categories of Data Recipients
                  02.4.5. Retention periods
         02.5. Prospects
                  02.5.1. Purpose of data processing
                  02.5.2. Legal basis for processing
                  02.5.3. Categories of Personal Data
                  02.5.4. Categories of data recipients
                  02.5.5. Retention periods
         02.6.    Clients
                  02.6.1. Purpose of data processing
                  02.6.2. Legal basis for processing
                  02.6.3. Categories of Personal Data
                  02.6.4. Categories of Data Recipients
                  02.6.5. Retention periods
03. Will Personal Data collected be disclosed to Third Parties?
04. Transfer of Personal Data outside of the EEA
05. Automated decision-making
06. Security measures
07. Keeping your Personal Data up to date
08. Exercising your rights 
09. Data Protection Officer
10. Changes and updates
 

01. Introduction

Terms used in this privacy policy that begin with a capital letter shall have the definition given to them in the General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679).

01.1. Who are we?

Ekkiden is a group of companies that offers consultancy services in the fields of industrial, digital and sustainable transformation, ultimately owned by Ekkiden Group SA, a public limited company (société anonyme) incorporated in Switzerland and having its registered office at c/o ELCA Informatique SA, Avenue Général-Guisan 70A, 1009 Pully Lausanne, Switzerland (“Ekkiden”, “we”, “our” or “us”).

Click here to know more about our structure .

01.2. Why this privacy policy?

In accordance with the General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) and any other applicable national data protection law, Ekkiden undertakes to ensure the appropriate security and confidentiality of Personal Data. Ekkiden is aware of its duties and obligations and consistently strives to ensure that your data is used responsibly.

In this policy, we would like to explain, in all transparency, the reasons for collecting your Personal Data, the categories of data used, who has access to your Personal Data and the period for which your Personal Data is stored. This document also contains information relating to your rights and how you can exercise them.

01.3. How does this privacy policy apply to you?

This privacy policy applies to:

•    Website visitors – any individual visitors and users of our website whose Personal Data is collected by us in the course of the navigation around our website.
•    Candidates – applicants for any type of job or engagement via us whose Personal Data is collected during the recruitment process.
•    Ekkiden employees – individuals who are hired by us and whose Personal Data is collected in the course of their employment with us.
•    Suppliers, partners, and service providers - any natural person or legal entity that provides us with goods and/or the execution of works or the provision of services.
•    Prospects – any potential customer of Ekkiden.
•    Clients – entities to whom we provide consultancy services.

We refer to the above groups of individuals collectively as “you” unless the context dictates otherwise.

01.4. Who is involved in the collection and handling of your Personal Data?

Each entity of Ekkiden may collect and use your Personal Data in connection with their business activities or services.

This privacy policy is issued by Ekkiden Technologies SA and on behalf of all entities of Ekkiden and only applies where any such entity acts as the Data Controller of your Personal Data. The applicable Data Controller will largely be the entity involved in the collection and handling of your Personal Data.

Ekkiden entities may jointly determine, on the basis of a written agreement, the purposes and means of processing Personal Data as Joint Controllers.

In addition, to provide our services, we may use suppliers or service providers who will act as Processors.

There are instances where Ekkiden entities may act on behalf of a client to process Personal Data rather than as the Data Controller. In those cases, we will process your data on behalf of the Controller and only on the latter's instructions.

Where we are a Processor, we will refer you to the applicable Data Controller and their privacy policy if you have any data protection-related queries.  

02. What Personal Data do we collect and for how long?

Personal Data means “any information which are related to an identified or identifiable natural person”. It does not, therefore, include data where the identity of the individual has been removed (anonymous data).

We will collect, record, organize, structure, store, adapt, retrieve, consult, use, share and/or transfer (generically referred to as “processing”) the different types of Personal Data about you listed under the name of the category of individual that applies to you. 

Please note that although a type of data may be collected, it does not mean that it is collected.

We will only keep your Personal Data as long as is necessary to achieve the purposes for which it is processed. However, we may retain your Personal Data for a longer period if so required by law or regulation or to establish, exercise or defend our legal rights. In this case, your Personal Data will be stored in an intermediate archive where it may only be consulted by specifically authorised individuals, on a non-recurring basis and for specific reasons. At the end of the retention period, your Personal Data will be securely deleted.

02.1. Website visitors

When you visit our website, we collect your Personal Data either through cookies and “tracking cookies” or through the contact form you fill in at https://www.ekkiden.com/contact-us.

02.1.1. Purposes of data processing

Why do we collect your Personal Data when you browse our website?

Ekkiden collects your Personal Data to:

•    Ensure that our website runs smoothly,
•    Measure website performance and improve your experience,
•    Answer to the queries sent to us through the website form,
•    Send you relevant information about our services and offers.

02.1.2. Legal basis for processing

What gives us the authorisation to collect your Personal Data when you browse our website?

In accordance with Article 6 of the GDPR, Ekkiden is authorised to collect and use your Personal Data for the above-mentioned purposes based on your consent when you browse our website, fill out a contact form, or sign up for a newsletter.

To configure your cookies, go to your data privacy preferences at the bottom of the page on our website (“Cookie Preferences”).

02.1.3. Categories of Personal Data

What Personal Data do we process when you browse our website?

When you browse our website, send a request form or sign on to our newsletter, Ekkiden processes:

•    Personal Data memorised by cookies and tracking cookies (e.g., device-specific information, such as IP address, browser type), For more information, consult our Cookie policy  here.
•    Identification (surname, first name),
•    Contact details (your email address and telephone number),
•    Data to process your request (type of request and details that you provide us).

No Sensitive Personal Data within the meaning of Article 9 of the GDPR is collected intentionally.

02.1.4. Categories of data recipients

Who can access the Personal Data we collect when you browse our website or send us a request?

Only authorized persons from Ekkiden Marketing department have access to your Personal Data.

02.1.5. Retention periods

How long may we keep the Personal Data we collect when you browse our website?

Personal Data memorised by cookies and tracking cookies are kept for thirteen (13) months. For more information, consult our Cookie policy  here.

Personal Data collected through a form or when you subscribe to our newsletter will be kept for a duration of two (2) years after our last contact or until you withdraw your consent. At the end of the retention period, your Personal Data will be securely deleted or anonymized.

02.2. Candidates

2.2.1. Purposes of data processing

Why do we collect your Personal Data when you apply for one of our employment opportunities? 

Ekkiden collects your Personal Data to:

•    Manage the recruitment process and your application,
•    Assess your skills, qualifications, and overall fitness to work at Ekkiden,
•    Communicate with you as part of our recruitment process,
•    Start the onboarding if you are hired at the end of the selection process,
•    Create a CV bank,
•    Keep your CV for future opportunities.

02.2.2. Legal basis for processing

What gives us the authorisation to collect your Personal Data when you apply for one of our employment opportunities?

In accordance with Article 6 of the GDPR, Ekkiden is authorised to collect your Personal Data based on:

•    Precontractual measures taken at your request when you apply to our jobs, including in the Jobs section at https://ekkiden-jobs.web.app/,
•    Our legitimate interest in building our CV bank.

02.2.3. Categories of Personal Data

What Personal Data do we collect when you apply for one of our employment opportunities?

The categories of Personal Data that we collect when searching for new employees include:

•    Identification data such as name, age and/or date of birth, gender, personal E-mail address, residence address, telephone number,
•    Data relating to your educational background, including qualifications, professional certifications and trainings and proficiency in one or several foreign languages,
•    Data relating to your professional experience and skills such as employment, function and position held,
•    Data relating to your salary or remuneration package with your current or former employer and expectations. 

If you provide us with the contact details of references, it is your responsibility to obtain the prior consent of those Third Parties.

We do not intentionally collect Sensitive Personal Data, such as religious beliefs, sexual orientation, political opinions, trade union membership, health and genetic information or biometric data about you.

02.2.4. Categories of Data Recipients

Who can access the Personal Data we collect when you apply for one of our employment opportunities?

The following persons are authorised to access your data in connection with your application:

-    Individuals involved in the recruitment process,
-    Our suppliers (e.g., when you apply to one of our job offers through a third-party platform). If our suppliers access your Personal Data, we draft an agreement to ensure that adequate security measures and appropriate safeguards are set up.

02.2.5. Retention periods

How long may we keep the Personal Data we collect when you apply for one of our employment opportunities?

Personal Data is kept for one (1) year after our last contact unless you expressly request the deletion of the Personal Data before this period. At the end of the retention period, your Personal Data will be securely deleted or anonymized.

02.3. Ekkiden employees

02.3.1. Purposes of data processing

Why do we collect your Personal Data when you are employed by us? 

Data we collect in the recruitment process described above may be further used if the candidate is successfully hired by Ekkiden and additional data may be requested to:

•    Draft your employment contract and any other employment-related document,
•    File declarations required under labour law,
•    Handle payroll and all related filings,
•    Organise our work, and engagements,
•    Assess performance and propose training programmes,
•    Ensure the safety of people and access to our premises.

02.3.2. Legal basis for processing

What gives us the authorisation to collect our employees’ Personal Data?

In accordance with Article 6 of the GDPR, Ekkiden is authorised to collect your Personal Data based on:

•    The performance of the employment contract,
•    A legal obligation, if the processing is necessary for compliance with a legal obligation to which Ekkiden is subject,
•    Legitimate interest, if the processing is necessary for the legitimate interest pursued by Ekkiden.

In addition, in accordance with Article 9 of the GDPR, Ekkiden is authorized to collect sensitive data about you based on:

•    Your explicit consent,
•    to comply with Ekkiden’s obligations and rights, and those of the individuals, in the fields of employment, social security and social protection law,
•    the vital interests of the employee, if they are at stake.

02.3.3. Categories of Personal Data

What Personal Data do we collect?

The Personal Data of our employee that we process includes:

•    Identification data such as name, age and/or date of birth, gender, personal E-mail address, residence address, telephone number.
•    Data relating to your educational background, including qualifications, professional certifications and trainings and proficiency in one or several foreign languages.
•    Data relating to your professional experience and skills such as employment, function and position held.
•    Financial relating to your salary or remuneration package and bank account number.
•    Sensitive Personal Data, such as information about race or ethnic origin, biometric data, or data concerning your health.

02.3.4. Categories of Data Recipients

Who can access the Personal Data we collect?

The Recipients of the Personal Data of our employees are:

•    Ekkiden employees in the HR, Finance and Legal departments,
•    Ekkiden Third Parties, in order to provide their services and in strict compliance with the technical and organisational security measures determined by Ekkiden,
•    Any local public administration if required by law.

02.3.5. Retention periods

How long do we keep the Personal Data we collect?

Personal Data collected or entrusted to us by our employees are kept for five (5) years after the end of the collaboration. At the end of the storage period, your Personal Data will be securely deleted or anonymized.

02.4. Suppliers, partners and service providers

02.4.1. Purpose of data processing

Why do we collect your Personal Data?

When entering into agreements with our suppliers, partners and service providers, Ekkiden may process their Personal Data if they are natural persons, or their employees’ Personal Data, for the following purposes: 

•    Manage the business relationship,
•    Meet our legal, regulatory and ethics obligations.

02.4.2. Legal basis for processing

What gives us the authorisation to collect your Personal Data?

In accordance with Article 6 of the GDPR, Ekkiden is authorised to collect your Personal Data based on:

•    The contract you signed with Ekkiden,
•    The legitimate interest of Ekkiden in managing payments, expenses and fees,
•    Ekkiden’s legal obligation to prevent all conflicts of interest, and more generally to ensure compliance with ethical rules and applicable law and regulations,

02.4.3. Categories of Personal Data

What Personal Data do we collect?

The Personal Data of our suppliers, partners, and service providers that we process comprise:

•    Identification data such as surnames and first names, 
•    Professional data (e.g., position held),
•    Contact details (email address, telephone number, workplace), 
•    Bank account details.

02.4.4. Categories of Data Recipients

Who can access the Personal Data we collect?

The Recipients of the Personal Data of our suppliers, partners and service providers are:

•    Authorised employees from our Legal and Finance department,
•    Ekkiden employees involved in executing the agreement,
•    Ekkiden suppliers, in order to provide their services and in strict compliance with the technical and organisational security measures determined by Ekkiden.

02.4.5. Retention periods

How long do we store the Personal Data we collect?

Personal Data collected or entrusted to us by suppliers, partners and service providers are kept for ten (10) years after the end of the contractual relationship. At the end of the storage period, documents and files are securely deleted or anonymized, following our policies.

02.5. Prospects

02.5.1. Purpose of data processing

Why do we collect prospects’ Personal Data?

Ekkiden collects your Personal Data to:

•    Send you information about our services, through newsletters or marketing activities in line with your business and your preferences.
•    Invite you to events that we are organising.
•    Administer and manage the new client acceptance process.

02.5.2. Legal basis for processing

What gives us the authorisation to collect prospects’ Personal Data?

In accordance with Article 6 of the GDPR, Ekkiden is authorised to collect your Personal Data based on:

•    Your consent given when you fill out a form on one of our websites or sign up for a newsletter,
•    Our legitimate interest in providing information on our service offers.

02.5.3. Categories of Personal Data

What information do we collect if you are a prospect?

To inform you of our service offers, Ekkiden collects:

•    Your surname.
•    Your first name.
•    Your contact details (personal and/or professional email address).
•    Your telephone number (personal and/or professional).
•    The name of your employer or the organisation with which you are associated.
•    Your function.
•    Any other optional Personal Data you send us in connection with our direct marketing activities or when you sign up for one of our newsletters.

02.5.4. Categories of data recipients

Who can access the Personal Data we collect on prospects?

The Personal Data you provide us to keep you informed of our service offers, events and training courses may be accessed by:

•    Authorised persons from our Marketing and Sales departments for strictly internal use in connection with communication campaigns (service offers).

02.5.5. Retention periods

How long do we keep the Personal Data we collect on prospects?

Personal Data collected for communication campaigns is stored in the CRM tool for two (2) years after your last contact with Ekkiden or until you withdraw your consent, after which your Personal Data will be securely deleted or anonymized.

If you refuse to receive marketing messages from us, we keep a record of that choice in order to comply with it.

02.6. Clients

02.6.1. Purpose of data processing

Why do we collect clients’ Personal Data?

Ekkiden offers clients a broad range of consulting services. Once you enter into a contract with Ekkiden, we may collect and use the Personal Data of your employees, suppliers and clients. 

As this data is collected indirectly, it is the client’s responsibility to inform the Data Subjects of the processing of their Personal Data in accordance with the regulations. For example, we may collect the data of these individuals in connection with our engagements.

02.6.2. Legal basis for processing

What gives us the authorisation to collect clients’ Personal Data?

In accordance with Article 6 of the GDPR, Ekkiden is authorised to collect your Personal Data based on our legitimate interest in providing the contractually agreed services and creating the right conditions for the proper performance of our engagements.

02.6.3. Categories of Personal Data

What Personal Data do we collect?

To provide the contractually agreed services and create the right conditions for the proper performance of our engagements, Ekkiden collects:

•    Your identification data (surname, first name).
•    Your contact details (professional email, telephone number, etc.).
•    Data relating to your professional activity (name of organisation, department, function).
•    Any other Personal Data in connection with the consulting services provided by Ekkiden. 

02.6.4. Categories of Data Recipients

Who can access the Personal Data we collect concerning clients?

Personal Data you send us to obtain the service requested can be accessed by:

•    Authorised persons at Ekkiden for strictly internal use to carry out their engagements,
•    Our suppliers, partners and service providers.

02.6.5. Retention periods

How long do we keep the Personal Data we collect on our clients?

Personal Data collected from, or entrusted to us by our clients or their employees is kept for ten (10) years after the end of the contractual relationship. At the end of the retention period, documents and files are securely deleted, following our policies and the standards governing Ekkiden’s activities.

Personal Data in connection with a project in consulting services by Ekkiden will be kept for the time of the project and will be processed under the instructions of the client. 

03. Will Personal Data collected be disclosed to Third Parties?

For the above-mentioned purposes, Ekkiden may need services, counselling and/or assistance from Third Parties, including, but not limited to, data hosting, counselling on compliance with laws and regulations, development of the website, human resources services, supply services, internet providers’ services and others.

In this regard, to the extent necessary, we can transmit or disclose Personal Data we collected to any natural person or legal entity, to subcontractors and business partners that are Third Parties with respect to Ekkiden. An Ekkiden entity may also disclose Personal Data to another Ekkiden entity.

Every time we need to transmit or disclose some Personal Data we collected to Third Parties, except in case of legitimate Interest of the Third Party, Ekkiden will make sure to have in place a Data Processing Agreement with this Third Party under the provisions of Regulation (EU) 679/2016, asking the Third Party to comply with the principles and the provisions of the same Regulation and to align on appropriate security standards.

Our website and/or services may include links to Third Party websites, plug-ins and applications, such as in the form of banner advertisements. Clicking on those links, or enabling those connections, may allow Third Parties to collect or share data about you.  We do not control these Third Parties and are not responsible for their data protection compliance.  When you leave our website, or connect to a Third Party from us, it is your responsibility to familiarise yourself with their privacy policy, as we accept no responsibility for, and have no control over them or any information or data collected by or for them.

04. Transfer of Personal Data outside of the EEA

Generally, we will not transfer your Personal Data outside the EEA. However, Personal Data will be transferred outside of the EEA when our Ekkiden Swiss entities are involved in the data processing. The European Commission has issued an adequacy decision recognizing that Swiss data protection law ensures a high level of data protection.

The Personal Data we collect from you may be transferred outside the EEA either by us and/or by any of the Third Parties to whom your Personal Data may be disclosed to as listed in Annex 1. If we do transfer your Personal Data outside the EEA, Ekkiden commits itself to:

•    ensure an adequate level of protection by setting appropriate safeguards and complying with the provisions of Regulation (EU) 679/2016;

•    manage the transfer of Personal Data on the basis of:
a)    European Commission’s adequacy decisions; if not
b)    standard contractual clauses/ binding corporate rules; if not
c)    code of conduct approved by the relevant supervisory authority/ official security certifications.

•    manage the transfer of Personal Data on the basis of consent of the Data Subject whose Personal Data has to be transferred or on the basis of derogations under article 49 of Regulation (EU) 679/2016 if the transfer cannot be executed on the basis of the above cases a), b), c).

05. Automated decision-making

Are any wholly automated decisions made using your Personal Data?

A wholly automated decision is one based solely on algorithms applied to your Personal Data, without any human involvement.

No Personal Data processing at Ekkiden envisages wholly automated decision-making. 

06. Security measures

How do we secure your Personal Data?

We put in place an appropriate level of security around your Personal Data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage to it.

We implement technical and organisational measures to ensure a level of security appropriate to the risk of harm that might result from unauthorised or unlawful processing accidental or unlawful loss, destruction or alteration, unauthorised (or disclosure of) access or damage to your Personal Data including:

•    locks and security systems;
•    usernames and passwords;
•    virus checking;
•    auditing procedures and data integrity checks; and
•    recording of file movements.

We limit access to your Personal Data to those employees, agents, contractors and other Third Parties who have a business need-to-know.  They will only process your Personal Data on our instructions and via the access controls listed above.  They are also subject to a duty of confidentiality.

We have agreed on security-related measures with the Third Parties we share your Personal Data with to ensure that it is treated by those Third Parties in a way that is consistent with how we safeguard your Personal Data.

We have also put in place procedures to deal with any suspected Personal Data Breach and will notify you and any applicable supervisory authority where we are legally required to do so.

If you suspect any misuse or loss of or unauthorised access to your Personal Data, please let us know immediately by contacting us.

07. Keeping your Personal Data up to date

We take reasonable steps to ensure that your Personal Data is accurate, complete, and up to date. We may contact you from time to time to check that the Personal Data is still correct.

Please let us know of any changes to your details as soon as you reasonably can so that we can uphold our commitment to accuracy, completeness and currency.

08. Exercising your rights

What are your legal rights in respect of your Personal Data that we handle?

We set out below a list of the legal rights that all individuals have under data protection laws in relation to our handling of your Personal Data:

•    Right to be informed – about your Personal Data and details of the handling and processing of that Personal Data and information, including the safeguards used to protect any of your Personal Data in the event that we transfer it outside the EEA.
•    Right of access – to your Personal Data and to obtain information about how we handle and process it.
•    Right to have inaccuracies corrected – this is a right to have your Personal Data corrected if it is inaccurate and to have incomplete Personal Data completed;
•    Right of erasure – of your Personal Data, which is also known as the “right to be forgotten”;
•    Right to restrict handling and processing – of your Personal Data, which includes requesting us to suppress your Personal Data file;
•    Right to move, copy or transfer – your Personal Data to another organisation, also known as “data portability”;
•    Right to object – to the handling and processing of your Personal Data for certain purposes, in particular to Personal Data processed for direct marketing purposes and to Personal Data that is handled and processed for certain reasons based on our legitimate interests;
•    Right to withdraw consent – you may withdraw any consent or permission that you have previously provided to us in relation to our handling and processing of your Personal Data, such as for the purposes of marketing by electronic means;
•    Rights in relation to automated decision making – where such automated decision making has a legal effect on you or otherwise significantly affects you; and
•    Right to complain – in all circumstances, you may complain to:
-    us in relation to the handling of your Personal Data; or
-    the regulatory body which enforces data protection law in your locality.

France : Commission nationale de l'informatique et des libertés (CNIL) : 3 Place de Fontenoy, TSA, 75334 PARIS CEDEX 07, France, +33 (0)1 53 73 22 22

Germany: Der Bundesbeauftragte für den Datenschutz und die Informationsfreiheit (BfDI) : Graurheindorfer Straße 153, 53117 Bonn, Germany, +49 (0)228-997799-0 
Spain: Agencia Española de Protección de Datos: Calle Jorge Juan, 6, 28001, Madrid, Spain, +34 (0) 901 100 099
Switzerland: Federal Data Protection and Information Commissioner (FDPIC): Federal Data Protection and Information Commissioner, Feldeggweg 1, 3003 Bern, Switzerland, +41 (0)58 462 43 95
Procedure to exercise your legal rights

Contact us – if you wish to exercise any of your legal rights, please contact us at privacy@ekkiden.com.

Our request for further information – we may need to request certain information from you to help us confirm your identity and ensure that your right to access your Personal Data (or to exercise any of your other rights that apply).  This is a security measure to ensure that any Personal Data is not disclosed to any person who has no right to receive it.  We may also contact you to ask you for further information in relation to your request to speed up our response.

Response time – we will respond to all legitimate requests as soon as we can but not longer than one month after receipt of your request to exercise a right. This period may be extended to two months if your request is particularly complex, or you have made a large number of requests.  In this case, we will notify you of this delay and keep you updated.

Fees – you will not have to pay a fee to access your Personal Data or to exercise any other rights that apply.  We may, however, charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.  Alternatively, we may refuse to comply with your request in these circumstances.

09. Data Protection Officer

Do we have a Data Protection Officer?
We have appointed a Group Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this privacy policy for all Ekkiden entities of the group. 
If you have any questions about this privacy notice, including any requests to exercise your legal rights relating to your Personal Data, please contact the DPO using the details set out below. 
You can contact our DPO for any data related query or make a complaint about how your Personal Data is being handled using the details below:

•    email address: privacy@ekkiden.com
•    postal address: Ekkiden Group SA, c/o ELCA Informatique SA, Avenue Général-Guisan 70A, 1009 Pully Lausanne, Switzerland, marking it for the attention of the “Data Protection Officer”.

10. Changes and updates

This privacy policy replaces any privacy policy that we have previously issued from Ekkiden.

Any notices or statements relating to data, data protection, fair processing and/or privacy that we may issue at the time of collecting Personal Data about you will supplement this privacy policy.  They are not intended to override it.

We may change this privacy policy from time to time to reflect changes in the law and/or our Personal Data handling activities and data protection practices. The date of the latest update is shown at the top of this page. The latest version of the privacy policy is binding.