The purpose of this privacy policy is to inform our clients, employees, business partners and the general public how we protect and handle private and sensitive information. At Fresh Strategy, we are committed to protecting your privacy through stringent privacy practices and adherence to the requirements of the Swiss Federal Act on Data Protection (FADP) and to the EU General Data Protection Regulation (GDPR).
Fresh Strategy is a Swiss consultancy with offices in Biel/Bienne, Switzerland, and employees and contractors across Switzerland and Europe. Our business practices and processes and our client and employee and contractor data are shared between our contractors and employees in the European Union, Switzerland and other locations. Fresh Strategy is fully committed to the proper handling and privacy of the personal information that it collects or uses for all individuals within the European Union and Switzerland.
Scope and Applicability
This Privacy Policy applies to all data and information collected by Fresh Strategy that allows for identification of an individual visiting our website. Adherence to this policy applies to all contractors and employees who work for Fresh Strategy.
Our website contains links to other sites. Fresh Strategy does not share your personal information with these sites, nor do we have any control over the privacy policies of those sites. If you visit third parties’ websites via links on www.freshstrategy.ch you leave our sphere of influence and thus the scope of application of this directive. We encourage you to learn about the privacy policies of the companies responsible for those sites.
What type of information do we collect?
When you visit a Fresh Strategy website your web browser software may automatically provide us with non-personal information such as the browser name and version, your computer type, operating system and the previous website you visited if you clicked a link to our site from another website. We also automatically determine your internet IP address or your internet service provider’s IP address. Any of this information may be recorded in our system logs or securely collected on our behalf via third-party services. This information will only be used internally in anonymous, aggregate reporting.
You may choose to provide Fresh Strategy with additional personal information by completing our online forms. We will inform you of how your personal information will be used at the point of collection, and Fresh Strategy will only use your personal information as described in this Privacy Policy.
What cookies do we use?
Certain parts of our website use cookies to provide a more optimal web experience. A cookie is a small piece of data sent to your web browser and saved on your computer. On subsequent visits to our site, your browser will automatically re-transmit the cookie data to our site. We may use cookies to customize the content shown to you, to provide conveniences to your browsing experience or to track aggregate traffic trends on our site. You are not required to accept and store cookies to browse our websites.
We may include certain Social Media features and widgets, single sign on features, such as the “Facebook Connect” or “Google Sign-in”, the “Facebook Like” button, the “Share this” button or other interactive mini-programs (“Social Media Features”). These Social Media Features may collect information such as your IP address or which page you are visiting on our website, and may set a cookie to enable them to function properly. Social Media Features are either hosted by a third party or hosted directly on www.wix.com. Your interactions with these third parties’ Social Media Features are governed by their policies and not ours.
In addition, our services may enable you to share your personal information with third parties directly, such as via page framing techniques to serve content to or from Third Party Services or other parties, while preserving the look and feel of our Website and Services (“Frames”). Please be aware that if you choose to interact or share any Personal Information via such Frames, you are in fact providing it to these third parties and not to us, and such interactions and sharing too are governed by such third parties’ policies and not ours.
If you want to delete or block any cookies, please refer to the help and support area on your internet browser for instructions on how to locate the file or directory that stores cookies. Information on deleting or controlling cookies is also available at www.aboutcookie.org (note that this website is not provided by Fresh Strategy and we, therefore, cannot ensure its accuracy, completeness or availability).
Please note that deleting our cookies or disabling future cookies or tracking technologies may prevent you from accessing certain areas or features of our Services, or may otherwise adversely affect your user experience.
Why do we collect information?
We collect non-personal and personal Information for the following purposes:
Customize and optimize the content shown to you;
To further develop, customize and improve our services, based on visitors’ and users’ common or personal preferences, experiences and difficulties;
Provide conveniences to your browsing experience;
To be able to contact our visitors and users with general or personalized service-related notices and promotional messages;
To create aggregated statistical data and other aggregated and/or inferred non-personal Information, which we or our business partners and contractors may use to provide and improve our respective services;
To comply with any applicable laws and regulations.
We will only use your personal information for the purposes set out above where we are satisfied that:
our use of your personal Information is necessary to perform a contract or take steps to enter into a contract with you (e.g. to provide you with a service), or
our use of your personal Information is necessary to comply with a relevant legal or regulatory obligation that we have, or
our use of your personal Information is necessary to support legitimate interests that we have as a business (for example, to maintain and improve our services by identifying user trends and the effectiveness of our campaigns and identifying technical issues), provided it is conducted at all times in a way that is proportionate, and that respects your privacy rights.
Fresh Strategy does not sell or rent your personally identifiable information to anyone. We may disclose your personal data to third parties for legitimate business purposes. The types of third parties that may be used by Fresh Strategy, and the purposes for disclosing personal information, include but are not limited to:
Contractors of Fresh Strategy that assist with delivering the assigned service
Vendors that assist with time tracking, expenses, invoicing, or accounting
Vendors who provide project support or project management support
Vendors who provide analytics services for projects
Vendors who provide backup or storage services for data
When may we contact you?
We may contact you via email, telephone, text messages, and postal mail to poll your opinions through surveys or questionnaires, to send updates about our company and other promotional messages, to resolve a dispute, to collect fees or monies owed, or as otherwise necessary to contact you to enforce our User Agreement, applicable national laws, and any agreement we may have with you.
How long do we retain your information?
We may retain your Personal Information for as long as we need to execute the above purpose. In any case, we conduct a review of the personal information that we retain once a year. Where your personal information is no longer required we will ensure it is securely deleted.
Where do we store your information?
Fresh Strategy is hosted on the Wix.com platform. Wix.com provides us with the online platform that allows us to display and sell our services to you. Your data may be stored through Wix.com’s data storage, databases and the general Wix.com applications. They store your data on secure servers behind a firewall.
All direct payment gateways offered by Wix.com and used by our company adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of credit card information by our store and its service providers.
Right to Change Policy
We reserve the right to modify this privacy policy at any time, so please review it frequently. Any changes to the Swiss or EU privacy regulations or the addition of new or updated applicable laws will result in changes to the Fresh Strategy Privacy Policy. Fresh Strategy reserves the right to amend this Privacy Policy and its related business procedures at any time. Changes and clarifications will take effect immediately upon their posting on the website. If we make material changes to this policy, we will notify you here that it has been updated, so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we use and/or disclose it.
Fresh Strategy Employee and Contractors Policy Adherence and Enforcement
It is the responsibility of all Fresh Strategy employees and contractors to read and adhere to this policy. Any employee, business partners or contractors found to have violated this policy may be subject to disciplinary action, up to and including termination of contract.
Contacting us with questions, or to access or delete your personal information
If you have any questions about this Privacy Policy or would like to: access, correct, amend or delete any personal information we have about you, or don’t want us to process your data anymore, please contact us at hello@freshstrategy.ch or send us mail to:
Fresh Strategy Ltd liab. Co,
Neuenburgstrasse 150
CH – 2505 Biel
If you are not satisfied with Fresh Strategy’s response to your complaint, there are additional recourse mechanism. We comply to the Swiss Federal Act on Data Protection (FADP) and within the European Union to the EU General Data Protection Regulation (GDPR). Contact information for the Swiss Federal Data Protection Information Commissioner and the EU DPA are as follows:
Swiss Federal Data Protection and Information Commissioner
Adrian Lobsiger
Feldeggweg 1, CH – 3003 Bern
+41 58 462 43 95 (Mo. to Fr., 10am to 12am)
www.edoeb.admin.ch
European Data Protection Supervisor
Rue Wiertz 60
1047 Bruxelles/Brussel
Office: Rue Montoyer 63, 6th floor
Tel. +32 2 283 19 00
Fax +32 2 283 19 50
e-mail: edps@edps.europa.eu
Website: http://www.edps.europa.eu/EDPSWEB/
Additional lists of more specific DPAs by country, city or region can be found here- http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm and here- https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/links/data-protection—switzerland.html.