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Privacy Policy Renera Group

The Privacy Policy of the Renera Group have been enacted in German with the present,
non-binding English translation thereof. In case of controversy the German text shall prevail.

Privacy Policy Renera Group

Version from 20.10.2023

In this privacy policy, we, the companies of the Renera Group, explain how we collect and otherwise process personal data. This is not an exhaustive description; other data protection declarations, general contractual conditions or similar documents may regulate specific matters. Personal data refers to all information relating to an identified or identifiable person. If you provide us with personal data of other persons (e.g. family members, data of work colleagues), please ensure that these persons are aware of this privacy policy and only share their personal data with us if you are authorised to do so and if this
personal data is correct. This privacy policy is designed to meet the requirements of the
Swiss Data Protection Act (“DPA”) and the EU General Data Protection Regulation (“GDPR”). However, whether and to what extent these laws are applicable depends on the individual case.

1. Responsible person / right to information:

Renera AG, Aeschenplatz 6, CH-4052 Basel, is responsible for the data processing described here, unless otherwise stated in individual cases.
The DPA grants you the right to know free of charge whether and what personal data Renera Group companies processes about you. You also have the right to have incorrect data corrected or deleted.
Requests for information for all Renera group companies (but if possible, please specify which company you are referring to) should be sent to Renera AG, Aeschenplatz 6, CH-4052 Basel or by e-mail to compliance@renera.energy together with a copy of your proof of identity (identity card or passport). Information will only be provided after verification of identity.

2. Collection and processing of personal data

We primarily process the personal data that we receive from our customers and other business partners as part of our business relationship with them and other persons involved or that we collect from their users when operating our websites, apps and other applications. Insofar as this is permitted, we also obtain certain data from publicly accessible sources (e.g. debt collection registers, land registers, commercial registers, press, internet) or receive such data from other companies within the Renera Group, from authorities and other third parties. In addition to the data that you provide to us directly, the categories of personal data that we receive about you from third parties include, in particular, information from public registers, information that we learn in connection with official and legal proceedings, information in connection with your professional functions and activities (so that we can, for example to conclude and process transactions with your employer with your help), information about you in correspondence and meetings with third parties, creditworthiness information (insofar as we process transactions with you personally), information about you that people from your environment (family, advisors, legal representatives, etc.) provide to us so that we can conclude or process contracts with you or with your involvement (e.g. references, your address for deliveries, powers of attorney, information on compliance with legal requirements such as anti-money laundering and export restrictions, information from banks, insurance companies, sales and other contractual partners of ours on the utilisation or provision of services by you (e.g. payments made, purchases made), information from the media and the Internet about your person (insofar as this is appropriate in the specific case, e.g. in the context of an application, press release, marketing/sales, etc.), your addresses and, if applicable, interests and other socio-demographic data (for marketing), data in connection with the use of the website (e.g. IP address, MAC address of the smartphone or computer, information about your device and settings, cookies, date and time of the visit, pages and content accessed, functions used, referring website, location data).

3. Purposes of data processing and legal bases

We primarily use the personal data we collect to conclude and process our contracts with our customers and business partners, in particular in the context of providing energy advice and supply to our customers and purchasing products and services from our suppliers and subcontractors, as well as to fulfil our legal obligations in Switzerland and abroad. If you work for such a customer or business partner, your personal data may of course also be affected in this function. In addition, we also process personal data of you and other persons, where permitted and where we deem it appropriate, for the following purposes in which we (and sometimes third parties) have a legitimate interest corresponding to the purpose: Offering and further developing our offers, services and websites, apps and other platforms on which we are present; 
communicating with third parties and processing their enquiries (e.g. job applications, media enquiries);
review and optimisation of procedures for needs analysis for the purpose of direct customer contact and collection of personal data from publicly accessible sources for the purpose of customer acquisition;
advertising and marketing (including the organisation of events), provided you have not objected to the use of your data (if we send you advertising as an existing customer, you can object to this at any time and we will then place you on a blacklist against further advertising mailings);
Market and opinion research, media monitoring;
assertion of legal claims and defence in connection with legal disputes and official proceedings; prevention and investigation of criminal offences and other misconduct (e.g. carrying out internal investigations, data analyses to combat fraud); 
ensuring our operations, in particular IT, our websites, apps and other platforms;
video surveillance to safeguard domiciliary rights and other measures for IT, building and facility security and protection of our employees and other persons and assets belonging to or entrusted to us (e.g. access controls, visitor lists, network and mail scanners, telephone recordings);
purchase and sale of business divisions, companies or parts of companies and other transactions under corporate law and the associated transfer of personal data as well as measures for business management and, insofar as necessary, compliance with legal and regulatory obligations and internal regulations of the Renera Group. If you have given us your consent to process your personal data for specific purposes (for example, when you register to receive newsletters or carry out a background check), we will process your personal data within the scope of and based on this consent, unless we have another legal basis and require one. Consent that has been given can be revoked at any time, but this has no effect on data processing that has already taken place.

4. Cookies / tracking and other technologies in connection with the use of our website

a. Cookies

We typically use "cookies" and similar technologies on our websites to identify your browser or device. A cookie is a small file that is sent to your computer or automatically stored on your computer or mobile device by the web browser you use when you visit our website. This enables us to recognise you when you return to this website, even if we do not know who you are. In addition to cookies that are only used during a session and are deleted after your visit to the website ("session cookies"), cookies can also be used to store user settings and other information for a certain period of time (e.g. two years) (“permanent cookies”). However, you can set your browser so that it rejects cookies, only saves them for one session or otherwise deletes them prematurely. Most browsers are preset to accept cookies. We use permanent cookies so that you can save user settings (e.g. language, autologin) and so that we can better understand how you use our offers and content (which can also happen on websites of other companies; however, we do not tell them who you are, if we know this at all, because they only see that the same user is on their website who was also on a certain page on our website). Some of the cookies are set by us, some are also set by contractual partners with whom we work. If you block cookies, certain functions (e.g. language selection, shopping basket, ordering processes) may no longer work. In some of our newsletters and other marketing e-mails, we also include visible and invisible image elements, where permitted, which we can retrieve from our servers to determine whether and when you have opened the e-mail so that we can measure and better understand how you use our offers and tailor them to you. You can block this in your email programme; most are pre-set to do this. By using our websites and consenting to receive newsletters and other marketing emails, you agree to the use of these techniques. If you do not want this, you must set your browser or e-mail programme accordingly.

b. Google Analytics

We sometimes use Google Analytics or similar services on our websites. This is a service provided by third parties, which may be located in any country in the world (in the case of Google Analytics, it is Google Ireland (based in Ireland), Google Ireland relies on Google LLC (based in the USA) as processor (both “Google”), (www.google.com), with which we can measure and analyse the use of the website (not on a personal basis). For this purpose, permanent cookies, which are set by the service provider, are also used. The IP addresses of visitors are truncated by Google in Europe before being forwarded to the USA and therefore cannot be traced back. We have switched off the settings "data transfer" and “signals”. Although we can assume that the information we share with Google is not personal data for Google, it is possible that Google can use this data for its own purposes to draw conclusions about the identity of visitors, create personal profiles and link this data to the Google accounts of these persons. If you have registered with the service provider yourself, the service provider also knows you. The processing of your personal data by the service provider is then the responsibility of the service provider in accordance with its data protection provisions. The service provider only informs us how our respective website is used (no information about you personally).

c. Google Ads Conversion Tracking

This website uses Google Conversion Tracking. If you have reached our website via an advert placed by Google, Google Adwords will set a cookie on your computer. The cookie for conversion tracking is set when a user clicks on an advert placed by Google. These cookies lose their validity after 30 days and are not used for personal identification. If the user visits certain pages of our website and the cookie has not yet expired, we and Google can recognise that the user clicked on the ad and was redirected to this page. Each Google AdWords customer receives a different cookie. Cookies can therefore not be tracked via the websites of AdWords customers. The information collected using the conversion cookie is used to generate conversion statistics for AdWords customers who have opted for conversion tracking. Customers are told the total number of users who clicked on their advert and were redirected to a page with a conversion tracking tag. However, they do not receive any information that can be used to personally identify users.

d. Zoho

We have integrated Zoho Forms on our website. Zoho Forms is a service of Zoho Corporation Pvt. Ltd, Estancia IT Park, Plot No. 140 & 151 GST Road Taluk, Vallancherry Village Kanchipuram District, Chengalpattu, Tamil Nadu 603202, India. Zoho Forms is used to store data entered in forms, e.g. when contacting us via the contact form. The data provided may be stored in our customer relationship management system (CRM system; cloud storage in the Netherlands). Zoho may process your data outside Switzerland or the EU, including in the USA. We would like to point out that according to the FADP and in the opinion of the European Court of Justice, there is currently no adequate data security (level of protection) for data transfers to the USA. This may entail various risks for the lawfulness and security of data processing. Zoho uses so-called standard clauses as the basis for data processing with recipients based in third countries (outside Switzerland and the EU). Standard clauses are templates provided by the EU Commission and are intended to ensure that your data complies with European  data protection standards even if it is transferred to third countries. Through the clauses, Zoho undertakes to comply with the European level of data protection when processing your relevant data, even if the data is stored or managed in the USA, for example. These clauses are based on an implementing decision of the EU Commission (https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj?locale=de). The standard clauses fulfil the corresponding legal requirements based on the recognition decision of the Swiss Federal Data Protection and Information Commissioner FDPIC.

e. Linkedin Ads Conversion Tracking

We use the conversion tracking technology and the retargeting function of the LinkedIn Corporation on our website. With the help of this technology, visitors to this website can be shown personalised advertisements on LinkedIn. Furthermore, it is possible to create anonymous reports on the performance of the adverts and information on website interaction. For this purpose, the LinkedIn Insight tag is integrated on this website, which establishes a connection to the LinkedIn server if you visit this website and are logged into your LinkedIn account at the same time. In LinkedIn’s privacy policy at https://www.linkedin.com/legal/privacy-policy you will find further information on data collection and use as well as the options and rights to protect your privacy. If you are logged in to LinkedIn, you can deactivate data collection at any time by clicking on the following link: https://www.linkedin.com/psettings/enhanced- advertising.

f. Social Media Plug-Ins

We also use so-called plug-ins from social networks such as YouTube, LinkedIn or Instagram on our websites. This is visible to you in each case (typically via corresponding icons). We have configured these elements so that they are deactivated by default. If you activate them (by clicking on them), the operators of the respective social networks can register that you are on our website and where and can use this information for their purposes. The processing of your personal data is then the responsibility of this operator in accordance with its data protection provisions. We do not receive any information about you from them.

5. Data transfer and data transmission abroad

As part of our business activities and for the purposes set out in Section 3, we also disclose data to third parties to the extent permitted and deemed appropriate, either because they process it for us or because they wish to use it for their own purposes. This applies in particular to the following bodies: Service providers of ours (within the Renera Group companies and externally, such as banks, insurance companies), including contract processors (such as IT providers); dealers, suppliers, subcontractors and other business partners; customers; domestic and foreign authorities, official bodies or courts; media; the public, including visitors to websites and social media; competitors, industry organisations, associations, organisations and
other bodies; acquirers or parties interested in acquiring business units, companies or other parts of Renera Group companies; other parties in potential or actual legal proceedings; other Renera Group companies; all collectively “Recipients”. These recipients are partly in Switzerland but can be anywhere in the world. In particular, you must expect your data to be transferred to all countries in which the Renera Group is represented by group companies, branches or other offices, as well as to other countries in Europe where the service providers we use are located (such as SAP). If a recipient is located in a country without adequate statutory data protection, we contractually oblige the recipient to comply with the applicable data protection law, unless the recipient is already subject to a legally recognised set of rules to ensure data protection and we cannot rely on an exemption provision. An exception may apply in particular in the case of legal proceedings abroad, but also in cases of overriding public interests or if the fulfilment of a contract requires such disclosure, if you have given your consent or if the data in question has been made generally accessible by you and you have not objected to its processing.

6. Duration of storage of personal data

We process and store your personal data for as long as is necessary for the fulfilment of our contractual and legal obligations or otherwise for the purposes pursued with the processing, i.e. for example for the duration of the entire business relationship (from the initiation, processing to the termination of a contract) and beyond that in accordance with the statutory retention and documentation obligations. It is possible that personal data may be stored for the period in which claims can be asserted against our company and insofar as we are otherwise legally obliged to do so, or legitimate business interests require this (e.g. for evidence and documentation purposes). As soon as your personal data is no longer required for the above-mentioned purposes, it will be deleted or anonymised as far as possible. For operational data (e.g. system protocols, logs), shorter retention periods of twelve months or less generally apply.

7. Data security

We take appropriate technical and organisational security precautions to protect your personal data from unauthorised access and misuse, such as issuing instructions, training, IT and network security solutions, pseudonymisation and checks.

8. Obligation to provide personal data

As part of our business relationship, you must provide the personal data that is necessary for the establishment and implementation of a business relationship and the fulfilment of the associated contractual obligations (as a rule, you do not have a legal obligation to provide us with data). Without this data, we will generally not be able to enter into or fulfil a contract with you (or the entity or person you represent). The website can also not be used if certain information to secure data traffic (such as IP address) is not disclosed.

9. Profiling

We process some of your personal data manually with the aim of evaluating certain personal aspects (profiling). We use profiling in particular to provide you with targeted information and advice about products. In doing so, we use evaluation tools that enable us to provide needs-based communication and advertising, including market and opinion research. As a matter of principle, we do not use fully automated decision- making (as regulated in Art. 22 GDPR) for the establishment and implementation of the business relationship or otherwise. Should we use such procedures in individual cases, we will inform you of this separately if this is required by law and inform you of the associated rights.

10. Rights of the data subject

You have the right to information, correction, deletion, the right to restrict data processing and otherwise to object to our data processing, in particular for the purposes of direct marketing, profiling for direct advertising and other legitimate interests in processing, as well as to the disclosure of certain personal data for the purpose of transfer to another organisation (so-called data portability) within the framework of the data protection law applicable to you and to the extent provided for therein (such as in the case of the GDPR). Please note, however, that we reserve the right to assert the restrictions provided for by law, for example if we are obliged to store or process certain data, have an overriding interest in doing so (insofar as we may invoke this) or require it for the assertion of claims. If you incur costs, we will inform you in advance. We have already informed you about the possibility of withdrawing your consent in section 3. Please note that exercising these rights may conflict with contractual agreements and may have consequences such as premature cancellation of the contract or cost consequences. We will inform you in advance if this is not
already contractually regulated. The exercise of such rights generally requires that you clearly prove your identity (e.g. by means of a copy of your identity card, where your identity is otherwise not clear or cannot be verified). To assert your rights, you can contact us at the address given in section 1. Every data subject also has the right to enforce their claims in court or to lodge a complaint with the competent data protection authority. The competent data protection authority in Switzerland is the Federal Data Protection and Information Commissioner (http://www.edoeb.admin.ch).

11. Changes

We may amend this privacy policy at any time without prior notice. The current version published on our website shall apply. If the privacy policy is part of an agreement with you, we will inform you of the change by e-mail or other suitable means in the event of an update.